Editor’s note: Each Spring, attorneys Bill Marler and Denis Stearns teach a Food Safety Litigation course in the LL.M. Program in Agricultural and Food Law at the University of Arkansas School of Law. This specialized program for attorneys brings together those who are interested in our food system, from farm to table. As a final assignment, students are asked to write an op-ed or essay on food safety, with the best to be selected for publication in Food Safety Website. The following is one of the essays for 2020.

By Nnenna Owoeye

As the COVID-19 pandemic sweeps across the world, “normal life” and “thinking” as we know it has been severely disrupted/impacted and every sector has taken a massive hit. The Agricultural and Food sector has not been immune to this hit at all and, this has evoked some critical thinking on the future of food. With a rising population predicted to hit 9 billion by 2050 and a threatening global food crisis, “edible insects” could be a key ingredient to avoiding or navigating through a global food crisis by creating alternative food sources.

Eating insects, also known as “Entomophagy” is not exactly mainstream, but is part of numerous traditional diets found in over 113 countries, including those in Africa, the Middle East, and South Asia, and consumed by approximately 2 billion people. For many, eating insects is not as a result of scarcity, or lack of access to other protein options, in fact in some parts of the world insects are more expensive protein options because they are traditional and beloved foods. Human relationship with insects varies widely from country to country. For some, it is a cultural staple as they acknowledge and appreciate their unique flavors-countries like Brazil eat queen ants, Ghanaians eat termites, (did I hear you think aloud, “same termites best known for destroying homes”)-yes, same, or perhaps the most renowned insect drink Mezcal, a Mexican liquor (sometimes confused with tequila), it is often served with a worm ready for swallowing. Do I sense the ick/yuck factor for some non-mainstream eaters?

Why eat bugs though?

Eating insects is as old as mankind with several cultures throughout the world consuming them, it could be eaten whole (fried, dried or roasted) or as an ingredient in processed food products such as burger patties, pasta, snacks or even the now popular North America cricket powder, which can be used like protein powder. According to the U.N. Food and Agriculture Organization (FAO), “more than 1,900 species of insects are edible and are a rich source of fat, protein, vitamins, fiber, and minerals comparable to commonly eaten livestock”. In the last decade, the global meat industry has been questioned for being responsible for at least 20 percent of manmade greenhouse gas emissions and overall, is an unsustainable practice. The inescapable conclusion is that these protein options are one of the least environmentally friendly ways to nurture our bodies.

Consumers globally are, therefore, looking with increasing delight for food and beverages featuring alternative, affordable, and sustainable protein sources. They are increasingly choosing and exploring alternatives to meat and dairy products- out of conviction or for health reasons, and particularly to benefit the environment and to be able to feed the world’s population responsibly in 2050 and beyond. The potential of edible insects cannot be understated as they are not only a possible ameliorant for the looming global food crisis, they are also accessible, eco-friendly, cheap, and very high in protein. A 2013 report by the UN’s Food and Agriculture Organization describes edible insects as a “good source of protein that could help sustain life”. The rich nutritional content of bugs, which even though it varies from species to species, can have up to twice the amount of protein as beef and 1.5 times the amount of protein like fish and poultry. Locusts, for instance, contains between 8 and 20 milligrams of iron for every 100 grams of raw locust. Beef, on the other hand, contains roughly 6 milligrams of iron in the same amount of meat. Crickets too are said to produce 11 times more food than cattle, for the same amount of feed and 1000 times less water.

Edible insects, with their high feed conversion efficiency and fecundity, as well as their minimal space for rearing, certainly represent an advantageous solution for present and future food insecurity. They are an environmentally sustainable food source, with a significantly lower carbon footprint compared to meat production and they produce less waste too, with the proportion of livestock that is not edible after processing approximately 30 percent for pork, 35 percent for chicken, 45 % for beef and 65% for lamb. By contrast, only 20 percent of cricket is inedible.

Are bugs safe to eat?

Even though billions of people eat insects across the world and it is also food that is as old as humanity, one would expect that Western countries will be more accepting of this novel food. But that is not the case, as most people in non-bug eating climes cannot get past the fact that insects are pests, filthy and a nuisance for humans, animals and crops alike, and is probably unsafe for human consumption-Definitely valid concerns to have. Hence, they are not moved by the otherwise compelling reasons to include insects in their diet. Food safety aspects of edible insects are largely unknown, but there is a lot of discourse in the food space on the possibility of their consumption, thus necessitating a need for proper regulatory guidelines as to safety for human consumption. Insects just like vertebrates can contain biological agents and substances that can represent a health threat to consumers. Experts have said that the risks associated with insect-eating depend on the species of insects, the feed they consume, the environment they inhabit, and the production and processing methods adopted. This complexity is the reason consumers are advocating for assurance of the safety of edible insects. It is important to mention that in cases where the insects are farmed, they are reared in controlled environments, in which sanitary techniques are usually employed, thus reducing some hazards such as microbiological contamination Therefore, the differences in the habitats the edible insects are harvested from can contribute to differences in their safety for consumption.

Are edible insects tipping to the mainstream?

European Union

Many still don’t exactly want bugs inviting themselves onto their plates-it is acquired taste. But, for those that are embracing it in countries that have no insect-eating culture, safety should be paramount. Europe is one of the few regions where there isn’t a long tradition of eating bugs, but that is set to change, as a few weeks ago European Food Safety Authority indicated being set to OK edible insects in the coming weeks. If this ruling does go through as anticipated, it would allow for mass-produced insect-based foods to be available throughout the EU. Companies working in this sector have been trying to get an E.U. wide approval for several years. As edible insects were already being consumed in some Western European countries like the Netherlands that has slowly embraced eating insects like mealworms, grasshoppers, and Buffalo worms; Denmark is also rapidly becoming the epicenter of another beverage- “cricket juice”. To do this, these states, including Belgium and Finland have taken a permissive approach to a 1997 EU law that requires foods not eaten before that year to get novel food authorization. The ruling is likely to lead to the final authorization of their sale across the EU as a “novel food” opening up opportunities for mass production of a range of insect dishes to be sold across Europe for the first time.

United States of America

The United States is still in the early stages of acceptance of eating bugs, as there are legislative barriers and majorly a cultural barrier of disgust at eating them; some believe it is a feat reserved for fear factor participants. However, insects are beginning to make an appearance on menus across the country, while stores like Hotlix in Pismo Beach, California are putting creepy-crawly sweets on the map. This is what advocates like Robert Nathan Allen of Little herds-Austin Tx, have to say in support of insects as a viable part of America’s diet “…the economics work out, the nutrition is ridiculously good and the resource efficiency is way better than other parts of the food industry, even our ancestors ate it”.

COVID-19’s effect on the food system includes restrictions on meat processing supply and meatpacking, leading to shortages. Consumer’s demand for protein has not reduced and alternatives are being considered by many. Some economists have predicted that May 2020 could be a period when consumers will have fewer options when buying meat. According to Politico, consumers will see shortages of pork, chicken, and beef on grocery shelves this month with major packing plants swept by the coronavirus remain shut while the nation’s massive stockpiles of frozen meat begin to dwindle. The perceived breakthrough in the edible insects’ industry in Europe presents new opportunities for the food industry and may have a rippling effect in countries like the US, which are in the early days of accepting insects as a viable part of our diet and a packed protein option. Insects’ high nutritional value which is higher than other protein options could plug the gap left by US meat producers during this pandemic.

Are there any legal barriers to insect consumption in the US?

There are significant barriers to overcome to become part of the mainstream, one of these is the regulatory landscape as it relates to edible insects in the US. The US Food and Drug Administration (FDA) grants oversight for insect consumption but not actively, rather current regulations for food are applied to edible insects. FDA, typically responds to edible insect inquiry by stating that insects are considered food if they are to be used for food or as components of food and yet on the other hand regulates insects as filth. This blanket and ambiguous response goes to the heart of intolerance of insects as a likely food option and has been viewed by many observers as a lackadaisical acceptance of the consumption of insects by humans. The notable barrier to effective regulation of insects for human food appears to be FDA’s silence on insects as anything but food defects. The agency has received inquiries about insects for use as human food for decades but still has made little progress in regulating this food source, in this COVID- 19 era and with the meat supply concerns currently plaguing the US, edible insects may have been a viable option. 

Worthy of note is USDA involvement in insect farming through their Animal and Plant Health Inspection Service (APHIS) agency. For example, if you want to import a new species of insect that is not currently in the US, you would need to contact APHIS.

Attitudes towards eating insects and current farming techniques and technologies need to change if edible insects are to become a common food source and get the necessary legislative attention.  

1. Van Huis, Arnold. Potential of Insects as Food and Feed in Assuring Food Security, Annu Rev Entomol Vol .58(1)5663-583.

2. E. S. Committee. “Risk Profile Related to Production and Consumption of Insects as Food and Feed.” EFSA Journal 13(10):4257, 2015.

 3. Rumpold, BA, and OK Schluter. “Nutritional Composition and Safety Aspects of Edible Insects.” Mol Nutr Food Res 57(5):802

 4. Crampton, Liz. “See your bacon: A real meat shortage looms with virus shutdowns”, Politico, April 23, 2020

 5. Crampton, Liz. “See your bacon: A real meat shortage looms with virus shutdowns”, Politico, April 23, 2020.

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